UK SRS · Consultation history
UK SRS consultation: how the standards were made
The UK SRS consultation ran from 25 June to 17 September 2025, drew 209 responses, and produced the standards the Department for Business and Trade published on 25 February 2026.
It was the first of several: the FCA’s CP26/5 consulted on making UK SRS S2 mandatory for listed companies, and its final rules of 30 September 2026 adopted comply or explain instead.
This page follows the sequence, and shows what each step settled and what it only proposed.
The sequence
One standard, several consultations
“The UK SRS consultation” usually means the exposure draft consultation, but the standards passed through several separate consultations run by different bodies.
The Department for Business and Trade consulted on the text of the standards, and published them when that consultation was answered — see the UK SRS timeline for the dates that follow from it.
The FCA then consulted on whether listed companies should have to use them — the step that created an obligation, which its final rules set as comply or explain.
A third consultation, on modernising corporate reporting, is where any requirement for private companies would begin.
The process itself is set out in the government’s Framework and Terms of Reference: a Technical Advisory Committee assesses each ISSB standard, a Policy and Implementation Committee advises on implementation, and the Secretary of State decides.
The Technical Advisory Committee received its commission in May 2024 and published its final recommendations on 18 December 2024, after agreeing them at a public meeting on 5 December 2024.
From recommendation to rules
- 18 Dec 2024TAC recommends endorsement
Agreed on 5 December 2024, after a commission in May 2024. Proposes minor amendments.
- 25 Jun 2025Three consultations open
UK SRS exposure drafts, assurance oversight, and climate transition plans.
- 17 Sep 2025All three close
11:59pm. The exposure drafts drew 209 responses; assurance oversight drew 99.
- 21 Oct 2025Corporate reporting programme announced
Written statement HCWS973 promises a consultation the following year.
- 11 Dec 2025ISSB amends IFRS S2
Targeted GHG amendments, later absorbed into UK SRS S2.
- 5 Jan 2026DBT writes to the FCA
The reliefs will lose their time references in the final standards.
- 30 Jan 2026FCA CP26/5 opens
Assurance-oversight response published the same day.
- 25 Feb 2026UK SRS S1 and S2 published
With the government response. Voluntary use.
- 20 Mar 2026CP26/5 closes
No response count published by the FCA.
- 7 Sep 2026Modernising corporate reporting opens
Closes 30 November 2026.
- 30 Sep 2026FCA final rules — PS26/19
Comply or explain across the UK SRS for listed companies in scope.
- 1 Jan 2027FCA rules apply
Accounting periods starting on or after this date; first reports in 2028.
June 2025
The UK SRS exposure draft consultation
The exposure draft consultation ran from 1pm on 25 June 2025 to 11:59pm on 17 September 2025.
It sought views on draft UK SRS S1 and UK SRS S2, which were the ISSB’s IFRS S1 and IFRS S2 with UK changes marked in.
The consultation page says the government “proposes 6 minor amendments to the standards for application in a UK context”: four recommended by the Technical Advisory Committee and two by the Policy and Implementation Committee.
It also sought evidence on costs and benefits, to inform any later decision on whether to require entities to report against the standards.
The page describes it as part of “the first phase of consultations to modernise the UK’s framework for corporate reporting”, published alongside consultations on assurance oversight and transition plans.
The response’s methodology annex describes the window as “approximately 8 weeks”, but the dates on the consultation page span twelve weeks, so quote the dates rather than the week count.
What the 20 questions covered
| Questions | Subject |
|---|---|
| 1–4 | The four amendments recommended by the TAC, and financed emissions |
| 5–9 | The two PIC amendments, carbon credits and the ISSB’s draft IFRS S2 amendments |
| 10 | Whether to endorse the standards overall |
| 11–20 | Costs and benefits, private companies, SMEs, legal liability and guidance |
Who answered
209 responses, and how to read them
The government response reports the total, the channel and a per-question agreement rate, but not every percentage means what it first appears to.
| Question | Agreed | Disagreed |
|---|---|---|
| Q1 — the four TAC amendments | 68% (125 of 184) | Not stated |
| Q5 — SASB “shall” becomes “may” | 70% (122 of 175) | 17% (30 of 175) |
| Q6 — link reliefs to the date any requirement comes into force | 83% (138 of 166) | 2% (4 of 166) |
| Q10 — endorse UK SRS S1 and S2 | 88% (159 of 180) | 4% (8 of 180) |
Demographic information exists only for the 170 online respondents, so the response’s tables on respondent type and sector are shares of 170, not of 209.
Of those 170, the largest single sector was financial and insurance services, at 42 respondents.
Of the 39 emailed responses, 25 followed the survey structure and 14 were read separately, according to the response’s methodology annex.
One number matters for private companies: of the online respondents who answered the question on economically significant private companies, fewer than 20 classed themselves as unlisted companies (¶1.60).
The response makes no claim that 209 is a high or low figure for a corporate reporting consultation, and neither do we.
The parallel assurance-oversight consultation, over the same window, received 99 responses.
February 2026
What the government response changed
Six amendments were proposed; the final standards do not simply contain those six.
| Proposed in June 2025 | What happened in the final standards |
|---|---|
| TAC 1 — remove the IFRS S1 relief allowing sustainability information to be published after the financial statements in year one | Made as consulted. |
| TAC 2 — extend the climate-first relief from one year to two | Replaced by something wider: the time references were removed, so the standards no longer say how long the non-climate and Scope 3 reliefs last. |
| TAC 3 — remove the requirement to use GICS for financed emissions | Withdrawn: the ISSB made the change itself in December 2025, and the TAC “no longer recommends any further amendments to IFRS S2 regarding GICS”. |
| TAC 4 — remove the effective-date clauses | Made. “For voluntary reporters, UK SRS is available to use immediately” (¶1.21). |
| PIC 1 — SASB material: “shall refer to and consider” becomes “may” | Made at UK SRS S1 ¶¶55(a), 58(a) and UK SRS S2 ¶¶12, 23, 32; the draft change to S2 ¶37 was reverted. |
| PIC 2 — link reliefs to the date any reporting requirement comes into force | Made, and extended: renamed “Application and transition” appendices and new UK SRS S1 ¶¶73A–73B. |
Added after the consultation closed
The direction was signalled in advance: on 5 January 2026 DBT’s letter to the FCA said it would be “removing specific time-references about when the reliefs would apply in the standards”.
UK SRS S1 ¶73A now says an entity using the climate-only relief may not assert compliance with UK SRS S1, though it may still assert compliance with UK SRS S2 if it discloses the reliefs it uses.
UK SRS S2 ¶B59A requires a financial institution that cannot meet the financed-emissions requirements for the same period to explain why — the one place the UK text is stricter than IFRS S2.
That paragraph followed Technical Advisory Committee recommendations sent to DBT on 26 January 2026, which also recommended absorbing the ISSB’s December 2025 amendments to IFRS S2 (¶1.48).
Those GHG amendments are the ISSB’s, not UK changes, and the response incorporates them into UK SRS S2 without their effective-date and transition content.
For a voluntary user, removing the time references means the non-climate and Scope 3 reliefs can be used “indefinitely, with no time limit”, until the Companies Act, the FCA or another authority sets terms.
The full paragraph-by-paragraph map is in Annex A, and we set it against IFRS in UK SRS compared with IFRS S1 and S2.
Two legal clarifications
The response confirms that UK SRS S2 is a national reporting framework for section 414CB(6) of the Companies Act 2006, so a company using it need not duplicate its climate-related financial disclosures, provided the section’s other conditions are met.
It also confirms that UK SRS disclosures placed in the Strategic Report attract the protective provisions of section 463 on directors’ liability.
25 February 2026
UK SRS published — for voluntary use
The final standards and the government response were published on the same day, 25 February 2026, and the response says it “marks the completion of the endorsement process”.
The government’s UK SRS guidance states that “the standards are available for voluntary use, by any entity that chooses to do so”.
So UK SRS was published as a voluntary standard; the listing-rule obligation came later, from the FCA — see reporting against UK SRS voluntarily for what adopting it now involves.
The standards themselves are described in our guides to UK SRS S1, the general requirements, and UK SRS S2 on climate.
One document trap: the government response PDF’s cover reads “25 February 2025”, a year out, while the GOV.UK page and the PDF’s back cover carry 2026.
The response is filed on the consultation page, not on the publication page, which holds only the two standards.
The text of UK SRS S1 and UK SRS S2, issued by the Secretary of State for Business and Trade.
That any entity may use them, in whole or in part, from 25 February 2026.
That neither standard carries an effective date: any obligation must come from the Companies Act, the FCA or another UK authority.
Running alongside
The assurance-oversight and transition-plan consultations
The Assurance of sustainability reporting consultation proposed a voluntary oversight regime and register for providers of third-party assurance over sustainability disclosures.
Its government response, published on 30 January 2026, confirms a “voluntary oversight regime” that practitioners may “opt in” to by registering with the financial reporting regulator.
The FRC was tasked with an interim, non-legislative regime by mid-2026; the latest record we hold, from July 2026, shows the register not yet open, so we do not say it exists.
Nothing in either consultation makes assurance mandatory, and CP26/5 ¶7.5 says the FCA is “not proposing to set mandatory requirements for the assurance of sustainability reporting at this time” — see assurance under UK SRS.
The third consultation in the June 2025 package, DESNZ’s climate-related transition plan requirements, still showed no outcome when we checked on 26 September 2026.
Our page on transition plans and UK SRS covers what the standards ask of a plan you already have.
The FCA’s UK SRS consultation
FCA CP26/5: the consultation that created an obligation
CP26/5 opened on 30 January 2026, twenty-six days before the final standards were published, and closed on 20 March 2026.
The FCA consulted on the drafts on purpose: “We are consulting now, based on the draft UK SRS” (¶1.3), while “not seeking to re-open discussion on the content of the UK SRS themselves” (¶2.19).
It proposed replacing the TCFD-aligned listing rules with mandatory reporting against UK SRS S2 for in-scope listed companies, except Scope 3, with Scope 3 and UK SRS S1 non-climate matters on a comply-or-explain basis.
Its cost benefit analysis (Annex 2 ¶43) estimated that around 600 listed companies would be affected.
The FCA said it aimed for the rules “to come into force from 1 January 2027” (¶3.7), and “to finalise our rules and publish our policy statement (PS) in autumn 2026. This is subject to the final UK SRS.” (¶1.11)
It did: PS26/19, published on 30 September 2026, adopts a comply-or-explain approach across the UK SRS for accounting periods starting on or after 1 January 2027 — so UK SRS S2 is not mandatory, and secondary listings and depositary receipts report too.
One consequence of consulting early: CP26/5 ¶8.6 describes the reliefs “as set out in the Government’s exposure drafts”, with periods of two years and one year that the final standards no longer contain.
That paragraph is accurate about the drafts and superseded as a description of the standards: for listed companies, the relief periods are set by the FCA’s final rules — one year for Scope 3, two years for S1 non-climate matters — not by the standards.
The consultation, the final rules, their scope and the Scope 3 treatment are covered in depth on our page on the FCA and UK SRS, with the Scope 3 detail in Scope 3 under UK SRS.
September 2026
Modernising corporate reporting: the private-company question
The programme was announced on 21 October 2025 in written statement HCWS973, which promised “an ambitious and holistic consultation planned for next year”.
The UK SRS government response then said the government would consider whether to require private companies to report against UK SRS as part of that exercise, “as we wish to ensure that regulatory changes are considered holistically”.
The Modernising corporate reporting consultation was published on 7 September 2026 by the Department for Business, Innovation, Science and Trade, and closes at 11:59pm on 30 November 2026.
On UK SRS the consultation document says, at ¶155, that “the government will consider how UK SRS should be reflected in the Companies Act 2006”.
That is the whole of it: no government document proposes any threshold or date for private companies.
The consultation’s wider proposals are covered on our Modernising corporate reporting page, and the position for unlisted businesses on UK SRS for private companies.
No proposal to require private companies to report against UK SRS.
No threshold, no date and no mechanism.
No proposals on the future of the Companies Act climate-related financial disclosure requirements, which are under a separate review due by spring 2027.
What comes next
After the consultations: what to watch
As at 30 September 2026, the FCA has decided; the government’s Companies Act question and the transition plan outcome are still open.
The Policy Statement — published
PS26/19 turned CP26/5 into final rules, and changed them: comply or explain across the UK SRS from 2027, with one-year and two-year reliefs.
Modernising corporate reporting closes
The government will then consider responses, including on how UK SRS is reflected in the Companies Act. No response date has been given.
Transition plans
The June 2025 consultation still shows no outcome. Any duty to have a transition plan would come from here, not from UK SRS.
What it means for a listed company
Plan against the FCA’s final rules, not CP26/5: comply or explain across the UK SRS for accounting periods starting on or after 1 January 2027, with first reporting in 2028.
A company’s current obligations are set out in UK sustainability reporting requirements, and who falls in scope in who must comply with UK SRS.
What it means for a private company
No UK SRS obligation exists or is proposed, and the only live route to one is the Modernising corporate reporting consultation, which is open for responses until 30 November 2026.
We track the FCA and government decisions as they land on our regulatory updates page.
Frequently asked
UK SRS consultation — frequently asked
What was the UK SRS consultation?
It was the Department for Business and Trade’s consultation on exposure drafts of UK SRS S1 and UK SRS S2, the UK versions of the ISSB’s IFRS S1 and IFRS S2. It ran from 1pm on 25 June 2025 to 11:59pm on 17 September 2025, proposed six minor amendments to the ISSB text for use in the UK, and also asked for evidence on costs, benefits, private companies, SMEs and guidance. The government response and the final standards were published together on 25 February 2026.
How many responses did the UK SRS consultation receive?
209. The government response (paragraph 1.6) says 170 were submitted through an online survey and 39 were sent to the Department for Business and Trade by email, and that 199 respondents were organisations and 10 were individuals. Demographic data covers only the 170 online respondents, so percentages in the response’s tables are shares of 170, not of 209.
What was the UK SRS exposure draft?
The exposure drafts were the draft UK SRS S1 and UK SRS S2 published for consultation on 25 June 2025: the ISSB’s IFRS S1 and IFRS S2 with six proposed UK amendments, four recommended by the Technical Advisory Committee and two by the Policy and Implementation Committee. The final standards differ from the drafts: one proposed amendment was withdrawn, one was replaced by a wider change, and new provisions were added after the consultation closed.
When was UK SRS published?
UK SRS S1 and UK SRS S2 were published on 25 February 2026, alongside the government response to the consultation. They are issued by the Secretary of State for Business and Trade and are available for voluntary use by any entity. Neither standard contains an effective date; the FCA’s final rules (PS26/19, 30 September 2026) require listed companies in scope to report against them on a comply-or-explain basis from accounting periods beginning on or after 1 January 2027.
What is the FCA consultation on UK SRS?
FCA consultation paper CP26/5, published on 30 January 2026 and closed on 20 March 2026, proposed replacing the FCA’s TCFD-aligned listing rules with requirements to report against UK SRS, with UK SRS S2 mandatory for in-scope listed companies except for Scope 3. The FCA’s final rules, PS26/19 of 30 September 2026, adopt a comply-or-explain approach across the UK SRS instead: listed companies in scope report against UK SRS, or explain why not, for accounting periods beginning on or after 1 January 2027, with first reporting in 2028.
Is there a consultation on UK SRS for private companies?
Not a specific one. The Modernising corporate reporting consultation, published on 7 September 2026 and closing on 30 November 2026, says only that the government will consider how UK SRS should be reflected in the Companies Act 2006. It contains no proposal, threshold or date for private companies to report against UK SRS.
Has the FCA published its Policy Statement on CP26/5?
Yes. The FCA published PS26/19, Aligning listed issuers’ sustainability disclosures with international standards, on 30 September 2026. Its final rules require listed companies in scope to report against UK SRS on a comply-or-explain basis for accounting periods starting on or after 1 January 2027, with first reporting in 2028. CP26/5 had said the FCA aimed to publish in autumn 2026.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner. Secondary commentary is never the source for a number.
- Department for Business and TradeExposure drafts: UK Sustainability Reporting Standards — consultation page
Ran 1pm 25 June 2025 to 11:59pm 17 September 2025; “proposes 6 minor amendments”; 209 responses; part of the “first phase of consultations”.
- Department for Business and TradeGovernment response to the consultation on UK Sustainability Reporting Standards (web version)
¶1.6 response breakdown; ¶¶1.17, 1.31, 1.35, 1.51 agreement rates; ¶1.21 effective dates; ¶1.48 TAC January 2026; Annex A final differences; Annex C method.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2 — publication page
Published 25 February 2026; the home of the two final standards.
- Department for Business and TradeUK SRS S1 General Requirements — final standard (PDF), ¶¶73A–73B and Appendix E
The statement-of-compliance paragraphs and untimed reliefs added after the consultation.
- Department for Business and TradeUK SRS S2 Climate-related Disclosures — final standard (PDF), ¶B59A and Appendix C
The financed-emissions explanation duty and the untimed Scope 3 relief.
- Department for Business and TradeUK Sustainability Reporting Standards — guidance, “What the UK is doing”
Voluntary use by any entity; the consultation ran alongside the assurance-oversight consultation; TAC and PIC roles.
- Department for Business and TradeFramework and Terms of Reference for the Development of UK SRS
The endorsement process the consultation formed part of.
- Department for Business and TradeLetter from DBT to the FCA on finalising UK SRS, 5 January 2026 (PDF)
Announced the removal of time references from the reliefs before CP26/5 was published.
- Financial Reporting CouncilUK Sustainability TAC issues final recommendations (18 December 2024)
The TAC’s endorsement recommendations, commissioned in May 2024 and agreed on 5 December 2024.
- IFRS FoundationISSB issues targeted amendments to IFRS S2 (11 December 2025)
The ISSB’s own GHG amendments, later absorbed into UK SRS S2.
- Department for Business and TradeAssurance of sustainability reporting — consultation page
Same window as the exposure drafts; 99 responses; outcome published 30 January 2026.
- Department for Business and TradeDeveloping an oversight regime for assurance of sustainability-related financial disclosures: government response
¶1.4 twelve weeks and 99 responses; ¶1.6 over 80% support; ¶¶1.8–1.9 voluntary, opt-in regime.
- DESNZClimate-related transition plan requirements — consultation page
Same window; still awaiting an outcome when checked on 26 September 2026.
- Financial Conduct AuthorityCP26/5: Aligning listed issuers’ sustainability disclosures with international standards — consultation page
Opened 30 January 2026, closed 20 March 2026; the FCA said it aimed to publish a Policy Statement in autumn 2026, and did so on 30 September 2026 (PS26/19).
- Financial Conduct AuthorityCP26/5 consultation paper (PDF), ¶¶1.3, 1.11, 2.19, 3.7, 7.5, 8.6 and Annex 2 ¶43
The proposals, their conditional timetable and the estimate of around 600 listed companies affected.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
First published 30 September 2026 — the Policy Statement on CP26/5. The final rules: comply or explain across the UK SRS, from accounting periods starting on or after 1 January 2027, first reporting in 2028.
- UK ParliamentWritten statement HCWS973: Regulation Action Plan Update, and Modernisation of Corporate Reporting (21 October 2025)
Announced the programme and a consultation “planned for next year”.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation page
Published 7 September 2026; closes 11:59pm on 30 November 2026.
- Department for Business, Innovation, Science and TradeModernising corporate reporting — consultation document (PDF), ¶¶147–155
CFD requirements out of scope; the government “will consider” how UK SRS is reflected in the Companies Act.
Continue reading
Read next
UK SRS timeline
From voluntary adoption to the FCA’s 2027 comply-or-explain start, date by date.
UK SRS vs IFRS S1 and S2
The final differences the consultation produced, paragraph by paragraph.
Voluntary reporting
What adopting UK SRS before any requirement involves.
UK SRS for private companies
Where unlisted businesses stand while the Companies Act question is open.
UK SRS assurance
The voluntary oversight regime and what the FCA’s final rules say about assurance.
Who must comply
The listed-company scope under the FCA’s final rules.